Wireless radiation- Extremely Important Action Opportunity – Deadline March 6, 2013

Are you concerned about radiofrequency (microwave) radiation emissions from smart meters, cellphones, WiFi, cellphone antennas, baby monitors etc or you are having health problems as a result of the FCC’s outdated physics-based radiofrequency radiation limits ? This is your chance to make your voice heard!

Support biologically-based radiofrequency radiation safety limits or the FCC could elect to raise its existing outdated physics-based safety limits. Please submit a reply in the reply round at the FCC by March 6, 2013.

Even if you commented during the comment period, please read on. If there are points that you wish you had included, you can file a reply as well. Even if you filed a Public Comment, you can reword a bit and refile, as a Reply Comment. The more, the better.

For the first time since the passage of the 1996 Telecom Act, the FCC is specifically requesting/allowing comment on its radiofrequency radiation limits.

This is a second opportunity for your voice to be heard on the question of the inadequacy of the outdated thermally-based FCC radiofrequency radiation exposure limits. Submitting your document in an official FCC proceeding is the only way to get information to the FCC that it is legally required to consider.

See http://stopsmartmeters.org/2012/03/09/a-primer-on-the-fcc-guidelines-for-the-smart-meter-age/ for background information on the FCC radiofrequency radiation limits.

We need to bowl them over with the numbers of replies in support of lowering the radiofrequency radiation limits so as to make them true safety limits – based on biology, as all true safety limits are.

Why do I keep saying reply? There is a comment period, which has passed. Following that there is a reply period. The only real difference is that you need to make a different selection upon filing and slightly different wording on the cover page of the submission. Both are reflected in the directions, below.

The FCC does not have the expertise to set safety limits so they have to adopt them from somewhere. Thus far, they have felt that they have only two options – the IEEE and the ICNIRP . At the EPA’s urging, they chose the more lower ones and adopted the IEEE exposure guidelines which are outdated and inadequate.

The Industry would like them to re-consider and adopt the more lenient ICNIRP guidelines.

In other words, the radiofrequency radiation limits could be RAISED if the FCC does not receive enough compelling comments asking that they be lowered.

The opportunity to comment on the FCC radiofrequency radiation limits was provided in footnote 95 (see http://www.emrpolicy.org/news/action/fcc_12_152_pp1_2_19.pdf to read text), buried in a docket on spectrum allocation, probably in the hope that there would be a minimal response, which would allow the FCC to ignore the issue for many more years.

Important Points:
Below are some points that you might want to include in your reply comment, then personalize/support them with a brief account of your own experience and your favorite references (which you can also upload for the FCC to read).

  • IARC of the World Health Organization classified radiofrequency radiation as a class 2B possible carcinogen in May 2011.
  • 2012 BioInitiative Report classifies radiofrequency radiation as a carcinogen. (Here is a sample wording to use to include 2012 BioInitiative Report in your comment without uploading the whole thing: The 2012 BioInitiative Report is incorporated by reference herein in its entirety (http://www.bioinitiative.org /))
  • “Public safety standards are 1,000 – 10,000 or more times higher than levels now commonly reported in mobile phone base station studies to cause bioeffects.”(http://www.bioinitiative.org/conclusions/) – You can find other great quotes relevant to your situation to include by visiting their conclusions section.
  • The Fenton Reaction, which is partially responsible for the carcinogenic nature of exposure to low levels of ionizing radiation, also occurs with exposure to radiofrequency radiation. See 2012 BioInitiative Report.
  • The FCC has a duty to the public to protect the public health and safety from harm from radiofrequency radiation.
  • US citizens and tax payers deserve radiofrequency radiation safety limits based on biology, not physics. In order for the FCC to fulfill its Congressional mandate to protect the public health and safety from harm from radiofrequency radiation it must update its RF safety regulations.
    “In the Telecom Act of 1996 Congress directed the FCC to set its own RF safety regulations for emissions from Personal Wireless Services Facilities (PWSF). The House Committee on Commerce said it was the Commission’s responsibility to adopt uniform RF regulations “with adequate safeguards of the public health and safety.” (H.R. Report No. 104-204, p. 94)
    The FCC’s failure to protect the health and safety of citizens by providing updated biologically- based RF safety limits on electromagnetic radiation exposure goes to the heart of the Chevron and Massachusetts v. EPA rulings on an agency’s authority to disregard its Congressional mandate. Such agency action and inaction are “arbitrary and capricious…[and] otherwise not in accordance with law.” (Massachusetts v. EPA, 549 U.S. 497, 534-535 (2007))
    The statute requiring the FCC to adopt and update RF safety regulations is not ambiguous, and therefore the clear intent of Congress applies.” EMR Policy Institute Comment in FCC Docket
  • FCC does not possess the expertise to set biologically-based radiofrequency radiation safety limits. EPA does. Therefore, the FCC should advocate that Congress direct the EPA to establish biologically-based radiofrequency radiation safety limits and provide the budget and resources to carry out that task. 2012 HR6358 was an excellent example of legislation to authorize the EPA to establish biologically-based radiofrequency radiation safety limits
  • Compliance with FCC radiofrequency radiation limits is often cited as an excuse to ignore evidence of harm by transmitting utility meters…etc and force harmful exposure on people against their will. Be sure to support with documentation from your experience.
  • A moratorium should be placed on sales of new spectrum, transmitting utility meter installation, and installation of additional base stations for wireless service while biologically-based safety limits are being developed.


Don’t wait until the last minute or the server may be too busy to take your comments.

These proceedings allow the public to inform the FCC why it must update its RF safety guidelines in order to comply with its proposal “to amend its rules to ‘ensure that the public is appropriately protected from any potential adverse effects from RF exposure.’” For example, FCC’s current RF safety guidelines do not take into account published research on the bioloigcal effects brought on by the ability of RF signals to communicate with living tissue.

Write your Reply, using this template for the first page( http://www.emrpolicy.org/news/action/template_comment_%20fcc_12_357.doc ). – Change “Comment filed by” to “Reply filed by” if it has not already been done for you.
Using the webpage submission form requires that you attach your Reply either in WORD or PDF. To do so, be sure you use this template for the first page of your Reply. PDF is the most secure form as no one can make changes to your Reply after you submit it.
Submissions from individuals have the greatest impact when filed in the form of an Affidavit. Page 2 of the template gives you the format for an affidavit.

Submit your Reply in FCC Proceedings ET Docket No. 03-137 and WT Docket No. 12-357, using instructions below. See explanation in this excerpt of WT Docket No. 12-357 at paragraph 53 and footnote 95 on the 3rd page of this excerpt. Complete text of FCC 12-152

Webpage (http://fjallfoss.fcc.gov/ecfs/upload/display?z=a7cs6) where you can submit your FCC Reply electronically.

Once on Webpage follow the directions below to submit your Reply:

• First fill in the box for the Proceeding Number with 03-137. Then click on the link <Add Another Proceeding> as you also type in 12-357.
• In the Contact Info section type in your name in the <Name of Filer> box and your e-mail address in the <Email Address> Box. 

• In the Details section ignore Exparte Presentation. For <Type of Filing> COMMENT will be showing in the box. Change it to REPLY. In the File Number box type – 12-152. Ignore the Report Number and Bureau ID Number boxes.
• In the Address section you want <Address for: Filer>. Most of you will also want <Address Type: US Address>. Then type in your own address information in the remaining boxes in this section.
• In the Document(s) section click on the Browse button and find the name of your document where you have saved it on your computer in your own Folders. Click on the name of your document. If you have addition information that you wish to submit such as some kind of Exhibit, click on the <Add Another Attachment> link and follow the same procedure.
• If you have made an error, click on <Reset> at the bottom of the page to clear the form and start over.
• Lastly click on the <Continue> button at the bottom of the page to review your submittal and to finish the process.
• Print out the confirmation page so that you have a record of the number assigned to your submittal.

Directions were adapted from those provided by The EMR Policy Institute with minor changes – original at http://www.emrpolicy.org/news/action/index.htm

(Courtesy of Lisa Anderson, San Diego, CA)

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